2007 (1) TMI 134

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..... s/2002, dated April 28, 2006. The Revenue is the appellant. The assessment year involved is 1997-98. The assessee is carrying on business of manufacture and sale of jewellery, gold ornaments at Chennai under the name of Bapalal and Co. and also exporting diamonds and precious stones from Bombay under the name of Suresh Bapalal. During the relevant assessment year, he claimed Rs. 49.75 lakhs as .....

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..... appeal by the Revenue raising the following substantial question of law: "Whether on the facts and in the circumstances of the case, the Tribunal was right in holding that the provisions of section 80HHC (3) are not applicable to the assessee's case?" Mr. J. Narayanaswamy, learned standing counsel appearing for the Revenue fairly submits that the issue is squarely covered against the Revenue .....

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..... all be the export turnover in respect of such trading goods as reduced by the direct costs and indirect costs attributable to such export ;" This court, in CIT v. Rathore Brothers [2002] 254 ITR 656, referred to supra, finding that the assessee therein had maintained separate accounts and it had maintained its trading receipts and profit and loss accounts separately for export sales and domestic .....

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